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  • Writer's pictureVidal, Nieves & Bauzá LLC


Vol. 26 - March 2020 | ©2020 by Vidal, Nieves & Bauzá, LLC. All rights reserved.

On March 30, 2020, the Municipal Revenue Collection Center (“CRIM”, by its Spanish acronym) issued Administrative Order No. 2020-04 whereby it announced a moratorium on the payment of interest, surcharges and penalties on real property tax payments which is in place until May 29, 2020. The order was issued in response to the Governor’s Executive Order OE 2020-29, which extended the lockdown and curfew related to the COVID-19 pandemic until April 12, 2020.

Applicability: The moratorium applies to the payment of real property taxes for the second semester of fiscal year 2019-2020 (January 2020), originally due on March 31, 2020.

Deadline: The deadline for taxpayers to may make their real property tax payment without being imposed interest, surcharges or penalties is now May 29, 2020.

Taxpayers with payment plans: Taxpayers with payment plans will automatically be able to benefit from the moratorium in effect until May 29, 2020. However, the months subject to the moratorium will be added at the end of the projected date to finalize the duration of any such payment plan.

Conditions applicable to supplemental invoices (“Suplementos”):

a) Supplements issued on January 1, 2020: will pay principal but will not accrue interests, surcharges nor penalties until May 29, 2020.

b) Supplements issued on February 1, 2020: will keep their 5% discount and not accrue interest, surcharges, or penalties until May 29, 2020.

c) Supplements issued on March 1, 2020: will retain their 10% discount and will not accrue interest, surcharges, or penalties until May 29, 2020.

d) The deadline to request an administrative review of the supplements issued on March 1, 2020 will be extended until May 29, 2020. As such, the 30-day deadline for the CRIM to determine whether it will accept the request for administrative review will commence upon the filing of the request.

Should you or your company have any questions or interest with respect to the moratorium announced by the CRIM, you may contact the attorneys at Vidal, Nieves & Bauzá, LLC, a corporate law firm with a special emphasis in energy and environmental matters, corporate, tax, transactional, real estate and insurance practices.

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